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The attribution of profits to permanent establishments paper

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Published on 19 Feb 14 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • principles for attributing profits to PEs (excluding Subdivisions 815-B and 815-C)
  • practical issues in PE profit attribution
  • effect of Subdivisions 815-B and 815-C of ITAA 1997
  • effect of adopting the AOA
  • adoption of the AOA by other countries.

Author profile

Ian Fullerton CTA
Ian is a Barrister, Ground Floor Wentworth Chambers. - Current at 29 October 2019
Click here to expand/collapse more articles by Ian FULLERTON.

 

This was presented at 2014 Financial Services Taxation Conference .

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